PRIVACY POLICY

STAR BRITE, INC DATA PROTECTION POLICY

Policy AimsSTAR BRITE is committed to being transparent about how it collects and uses the personal data of its customers and its workforce, and to meeting its data protection obligations. This policy sets out the organization’s commitment to data protection and individual rights and obligations in relation to personal data.

STAR BRITE is committed to complying with data protection legislation and good practice including:⦁ Processing personal information only where this is strictly necessary for legitimate organizational purposes⦁ Collecting only the minimum personal information required for these purposes and not processing excessive personal information⦁ Providing clear information to individuals about how their personal information will be used and by whom⦁ Only processing relevant and adequate personal information⦁ Processing personal information fairly and lawfully⦁ Maintaining an inventory of the categories of personal information processed by STAR BRITE⦁ Keeping personal information accurate and, where necessary, up to date⦁ Retaining personal information only for as long as is necessary for legal or regulatory reasons or, for legitimate organizational purposes⦁ Respecting individuals’ rights in relation to their personal information, including their right of subject access⦁ Keeping all personal information secure

Responsibilities under the General Data Protection Regulation (GDPR)⦁ STAR BRITE is a Data Controller and a Data Processor under the GDPR.⦁ Senior Management and all those in managerial or supervisory roles throughout STAR BRITE are responsible for developing and encouraging good information handling practices within the organization.⦁ A member of the senior management team is accountable to the Directors for the management of personal information within STAR BRITE and for ensuring that compliance with data protection legislation and good practice can be demonstrated.⦁ STAR BRITE has a GDPR Owner who has been appointed to take responsibility for STAR BRITE’s compliance with this policy on a day-to-day basis.⦁ The GDPR Owner has specific responsibilities in respect of procedures such as the Subject Access Request Procedure and is the first point of call for Employees/Staff seeking clarification on any aspect of data protection compliance.⦁ Compliance with data protection legislation is the responsibility of all staff at STAR BRITE who process personal information.

When you express interest in STAR BRITE its products, we will collect and process the following data from you:⦁ your name;⦁ email address⦁ your country

Who will your personal information be shared with?If we are obliged to disclose personal data by law, or if the disclosure is necessary for purposes of national security, taxation and criminal investigation, we will do so. In some circumstances, you may not be notified first.Your data is hosted on several different systems. All these providers have relevant safeguards in place to protect your data in the same way that we do.

What happens with my data and how is it retained?⦁ Upon no longer conducting business with STAR BRITE your data will be stored safely and securely. We will retain your personal data a maximum of 2 yearsData protection principles

All processing of personal data must be done in accordance with the following data protection principles of the Regulation, and STAR BRITE’s policies and procedures are designed to ensure compliance with them. These are:1. Personal data must be processed lawfully, fairly and transparentlyThe GDPR introduces the requirement for transparency whereby the controller has transparent and easily accessible policies relating to the processing of personal data and the exercise of individuals’ “rights and freedoms”. Information must be communicated to the data subject in an intelligible form using clear and plain language.

The specific information that must be provided to the data subject must as a minimum include:⦁ The contact details of the Data Protection Officer, where applicable⦁ The purposes of the processing for which the personal data are intended as well as the legal basis for the processing⦁ The period for which the personal data will be stored⦁ The existence of the rights to request access, rectification, erasure or to object to the processing⦁ The categories of personal data concerned⦁ The recipients or categories of recipients of the personal data, where applicable⦁ Any further information necessary to guarantee fair processing

1. Personal data can only be collected for specified, explicit and legitimate purposesData obtained for specified purposes must not be used for a purpose that differs from those formally notified to the Information Commissioner as part of STAR BRITE’s GDPR registration.

1. Personal data must be adequate, relevant and limited to what is necessary for processing⦁ The GDPR Owner is responsible for ensuring that information, which is not strictly necessary for the purpose for which it is obtained, is not collected.⦁ All data collection forms (electronic or paper-based), including data collection requirements in new information systems, must be approved by the GDPR Owner.⦁ The GDPR Owner will ensure that, on an annual basis all data collection methods are reviewed to ensure that collected data continues to be adequate, relevant and not excessive.

1. Personal data must be accurate and kept up to date⦁ Data that is kept for a long time must be reviewed and updated as necessary. No data should be kept unless it is reasonable to assume that it is accurate.⦁ Customers should notify STAR BRITE .⦁ It is the responsibility of staff at STAR BRITE to ensure that data held by STAR BRITE is accurate and up-to-date. Completion of an appropriate registration or application form etc. will be taken as an indication that the data contained therein is accurate at the date of submission.

1. Personal data must be kept in a form such that the data subject can be identified only as long as is necessary for processing⦁ Where personal data is retained beyond the processing date, it will be pseudonymized in order to protect the identity of the data subject in the event of a data breach.⦁ Personal data will be retained in line with the retention of records procedure and, once its retention date is passed, it must be securely destroyed as set out in this procedure.

1. Personal data must be processed in a manner that ensures its security⦁ Appropriate technical and organizational measures shall be taken against unauthorized or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.⦁ These controls have been selected on the basis of identified risks to personal data, and the potential for damage or distress to individuals whose data is being processed.⦁ Personal data shall not be transferred to a country or territory outside the European Union unless that country or territory ensures an adequate level of protection for the ‘rights and freedoms’ of data subjects in relation to the processing of personal data.⦁ The transfer of personal data outside of the EU is prohibited unless one or more of the specified safeguards or exceptions apply.

1. AccountabilityThe GDPR introduces the principle of accountability which states that the controller is not only responsible for ensuring compliance but for demonstrating that each processing operation complies with the requirements of the GDPR.Specifically, controllers are required to maintain necessary documentation of all processing operations, implement appropriate security measures, perform DPIAs (Data Processing Impact Assessment), comply with requirements for prior notifications, or approval from supervisory authorities and appoint a Data Protection Officer if required.

1. Data subjects’ rightsData subjects have the following rights regarding data processing and the data that is recorded about them:⦁ To make subject access requests regarding the nature of information held and to whom it has been disclosed.⦁ To prevent processing likely to cause damage or distress.⦁ To prevent processing for purposes of direct marketing.⦁ To be informed about the mechanics of automated decision-making process that will significantly affect them.⦁ Not to have significant decisions that will affect them taken solely by an automated process.⦁ To sue for compensation if they suffer damage by any contravention of the GDPR.⦁ To take action to rectify, block, erased, including the right to be forgotten,.⦁ To request the ICO to assess whether any provision of the GDPR has been contravened.⦁ The right for personal data to be provided to them in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller.⦁ The right to object to any automated profiling without consent.

1. ConsentSTAR BRITE understands ‘consent’ to mean that it has been explicitly and freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she by statement, or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. The consent of the data subject can be withdrawn at any time.

1. Security of dataAll Employees/Staff are responsible for ensuring that any personal data which STAR BRITE holds and for which they are responsible, is kept securely and is not under any conditions disclosed to any third party unless that third party has been specifically authorized to receive that information and has entered into a confidentiality agreement. Care must be taken to ensure that PC screens and terminals are not visible except to authorized Employees/Staff. Manual records may not be left where they can be accessed by unauthorized personnel and may not be removed from business premises without explicit authorization. As soon as manual records are no longer required for day-to-day customers hip support, they should be archived. Personal data may only be deleted or disposed of in line with the Data Retention Procedure. Manual records that have reached their retention date are to be shredded and disposed of as ‘confidential waste’.

1. Rights of access to dataData subjects have the right to access any personal data (i.e. data about them) which is held in electronic format and manual records which form part of a relevant filing system.

1. Disclosure of dataSTAR BRITE must ensure that personal data is not disclosed to unauthorized third parties. STAR BRITE will only disclose and discuss personal data with the Primary contact. The GDPR permits certain disclosures without consent so long as the information is requested for one or more of the following purposes:⦁ to safeguard national security⦁ prevention or detection of crime including the apprehension or prosecution of offenders⦁ assessment or collection of tax duty⦁ to protect the vital interests of the individual⦁ to safeguard our customers including contact with local safeguarding boards

All requests to provide data for one of these reasons must be supported by appropriate paperwork and all such disclosures must be specifically authorized by the GDPR Owner.

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